Taxation (International and Other Provisions) Act 2010 section 303

Qualifying EEA tax relief for payment in future period

Section 303 explains how to determine whether a company has qualifying EEA tax relief available in a future accounting period, for the purpose of the double taxation relief rules.

• This section applies when a company expects to receive tax relief in a future period under the law of an EEA territory, which would reduce the foreign tax on its income or gains.
• The relief counts as "qualifying EEA tax relief" if it will reduce the amount of tax that would otherwise be payable in that future period in the EEA territory concerned.
• The section ensures that where relief is not available in the current period but will be available later, it is still taken into account when calculating the company's entitlement to UK double taxation relief.
• This provision works alongside the broader framework for EEA tax relief, ensuring that timing differences in when foreign relief is granted do not distort the UK credit relief position.

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